Jan Robinson, Scientific and Regulatory Affairs Director at the International Association for Soaps, Detergents and Maintenance Products (A.I.S.E.) and Chair of the Downstream Users of Chemicals Coordination Group (DUCC) in Brussels, Belgium, is committed to using the best science and methods to ensure that companies’ products are safe to use.
Here, she talks with Vera Koester of ChemistryViews about what it means to move away from assessing the risks of chemicals to simply banning them based on the hazards they pose, the importance of science in politics, and her passion for chemistry, engaging with legislative documents, and playing the piano.
DUCC is celebrating its 20th anniversary. Congratulations! Can you say a few words about what DUCC is?
DUCC is a platform of eleven associations that represent industries that formulate mixtures, which is to say, detergents, paints, disinfectants, plant protection products, adhesives, sealants, lubricants, and cosmetics among others—a whole range of different products that are all mixtures of chemicals and used by consumers or professional or industrial end users.
DUCC was formed 20 years ago to allow the associations to work together and speak with one voice on the then-new community chemicals policy that was laid out in the European Commission’s white paper “Strategy for a Future Chemicals Policy,” which eventually led to the launch of the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation in 2007. The platform coalesced because all of these formulating industries had similar concerns, issues, needs, and specificities around the use of chemicals. They wanted to have a voice that was distinct from the chemicals industry, that is, the producers of the industrial and commodity chemicals that are used by these mixture-formulating industries.
Twenty years on, we are still working together. We have worked together on the implementation of REACH and CLP (classification, labeling, and packaging) predominantly. Now, of course, we are discussing and working together on what the EU Chemicals Strategy for Sustainability means for formulating industries.
DUCC represents over 9,000 companies and industries totaling well over 200 billion euros in the European market. Of course, they are all facing pressure from the regulation of chemicals but also from consumer demands to be more sustainable, to protect the planet and people as well as prosperity. We try to do that together to be more efficient, to offer regulators and other stakeholders a single dialogue partner because it is more helpful to talk to all of these industries with the same issues as one instead of talking to lots of individual industries separately.
So would you say that topics like regulation and sustainability connect these companies? Was DUCC a pioneer in that regard? And are there other organizations similar to DUCC?
Yes, the kind of connecting thing between all of these very different companies and industries is the sustainability aspect.
There are similar platforms, including informal groupings of associations based in Brussels. For example, there is one for the end users of chemicals, which represents producers of goods and articles. It brings together industries like printing, publishing, the footwear leather industry, and clothing. There are similar kinds of platforms of related industries working at the same tier of the chemicals industry.
What are the biggest challenges DUCC is facing at the moment?
Well, among the biggest challenges are some of the targeted revisions to REACH. We hear a lot about adopting a generic approach to risk management. This effectively means moving away from assessing the risks of chemicals or how they are used in products and instead moving towards simply banning them based on the hazards they pose. This is something that we have some concerns about because it does not make use of all the best science, all of the risk-assessment strategies, and all the risk-management approaches that exist in the industry. We want to continue making use of the best science and methodologies to make sure the products are safe to use.
“Free of hazards” does not necessarily mean “safe”. If you remove all the hazards from something, then it might be safe but it might also not be useful. It might not have the functionality that you really wanted.
Chemical substances can be regulated hazard-based or risk-based. In a hazard-based approach, substances are regulated based on their intrinsic properties, without considering exposure to the substance. In a risk-based approach, exposure is taken into account.
The European Commission gives the following example on its website: A lion is intrinsically a hazard. Safely caged in a zoo, it poses no risk because there is no “exposure.”
“Hazard-based” and “risk-based” decision making on chemicals: what is the regulatory context?, European Commission (accessed June 14, 2022)
Is it difficult to talk with the European Commission about topics? Is there room for discussion?
We have had a lot of success. DUCC is now quite well respected. We have had an ongoing dialogue for 20 years with the relevant Directorates General in the EC. In particular, we have regular discussions with DG Grow and DG Environment. [Ed. note: The department for growth (DG GROW) is responsible for the EU Commission’s policies on the single market, industry, entrepreneurship, and small businesses. DG Environment proposes and implements policies that ensure a high level of environmental protection and preserve the quality of life of EU citizens.]
We have held quite a lot of workshops, some of them proactively organized by DUCC, to talk about some of these elements of the REACH revision. These have been welcomed by the European Commission because we took the initiative to bring information to these forums and to have an open debate. We have also conducted surveys. For example, we ran a survey in March and April on what potential new mandatory reporting requirements on use and exposure information could mean for downstream users, and we presented the results to the European Commission.
Can you be a little more specific about what that’s about?
The Commission is considering new requirements under REACH for downstream users of chemicals to report the quantities and typical use/exposure patterns for the substances that they use, in order to supplement the information available from substance registration dossiers. The terms of reference for the impact assessment study and a document from the consultants on envisaged policy options are both publicly available.
How did you go from being a chemist to these regulatory topics?
I studied applied chemistry at university many, many years ago. When I began working initially as an analytical chemist, the Control of Substances Hazardous to Health (COSHH) regulations in the UK were just coming into effect. It was the UK implementation of the Chemical Agents Directive at the EU level, that is, the establishment of minimum requirements for the protection of workers from potential risks related to exposure to chemical agents at the workplace or during work-related activity.
From the very beginning of my career, I witnessed the development of chemical regulation to protect people in the workplace. That was quite interesting.
You work for the International Association for Soaps, Detergents and Maintenance Products (A.I.S.E.), the official representative body of this industry in Europe. How much is your job still connected to chemistry?
Well, my title is Scientific and Regulatory Affairs Director! So we aren’t just advocating about what we want to see in the legislation—although that is a very important part of what we do at A.I.S.E. At the same time, A.I.S.E. is recognized as a scientific institution under Belgian law, and we sponsor a lot of research. We bring together experts from our membership and external consultants, and we commission scientific research on, say, in vitro histopathology to look at the effectiveness of non-animal tests for characterizing, for example, the potential some products might have to act as eye irritants. This is certainly one of the most important hazards for consumer cleaning products.
How do you guarantee scientific independence in commissioned studies like that?
Scientific studies that we commission—most commonly to explore and validate alternatives to animal testing—are placed with external laboratories/institutes working in compliance with the principles of Good Laboratory Practice (Directive 2004/10/EC), setting standards of quality, reliability, and impartiality and also subject to inspection and verification by Member States. Whilst samples may be provided by members, they are always fully anonymised and are typically model formulations rather than real products.
The results of our research are written up as articles for scientific publications, which are subjected to peer review, and failures are reported as well as passes. In this way we endeavour to safeguard the highest standards of scientific rigour and best practice.
What fascinates you most about your job?
Oh, where to begin?
The interface of science and policy is really interesting to me. I don’t think I would have continued working in this job for so long if it were just purely the science or purely the policy aspect. The confluence of the two is what makes it so interesting and important. The fact that we are bringing real data and real science into the debate is what is really valuable to me. We are not just arguing on a point of opinion; we always try to argue from a position of facts and data.
Most of these facts and data are sourced from your members?
Yes, typically. Besides the research that we sponsor ourselves collectively as the industry, as I mentioned before, we collect data from our members. The input of our members is hugely important. They are conducting research, they are developing new products, they are collecting data from the market, and we rely on their input as an association.
Of course, we treat the information we collect anonymously. We collate it and present it in an aggregated and effective way, so the members don’t have to worry about competition. We are guided by the rules of competition law, and every meeting has to begin with respect to those rules.
One of the things I love about working in associations after, what, 15 years now, if you include my time working in associations on behalf of a company, is how willing companies are to collaborate on the points of common interest and ensure we all get good regulations. It’s important that we have a level playing field so we can compete evenly and fairly. It’s in everyone’s interests, and it’s always wonderful to see how willing companies are to open up.
Are you working with other associations or companies from other regions like China or the US?
Certainly. There are networks within each of the individual sectors. In A.I.S.E., we work with our international partners through INCPA, the International Network of Cleaning Products Associations. So we have regular meetings with partners in Australia, the US, China, Japan, and all around the world. There are similar networks in most of the other sectors.
Do you work together with academia?
Yes, we do. We have a number of initiatives in place. At DUCC level the involvement is perhaps a little less, but certainly within my own sector A.I.S.E., we have a lot of academics who are involved in the work that we do—for example, in some of the in vitro research that we have commissioned.
We also have a platform called DetNet, the Detergent Industry Network for CLP Classification, where companies can upload their data, their product compositions, and compare their mixtures anonymously with other compositions in the database. This effectively makes use of bridging principles to classify and label their products based on past experience. We have an advisory panel for that classification network which is made up of very experienced academics who advise on the classification principles.
For competitive reasons, of course, users can’t see other members’ products. They feed in the composition of their own products and they then get a result from the database that compares the input with the data behind the software interface.
What do you think you will be doing in ten years?
Well, I’d like to think I will be retired but I don’t think that is going to be the case. To be honest, I think there is going to be enough work to keep us busy and really engaged for the next ten to fifteen years. Most of the Green Deal targets and policies are talking about a goal of 2030. The Chemicals Strategy for Sustainability has a rollout timeline that only goes up to 2024, but I think the Green Deal is probably going to dominate the conversation for the next 20 years.
When DUCC is celebrating its 40th anniversary, I think we’ll be looking back on what has been achieved by the European Green Deal and how far we’ve come—certainly since the beginnings of the Green Deal but even since that very first white paper on chemicals policy back in 2001 that I mentioned at the beginning.
Which means that the next 20 years will probably be even more exciting than the first 20 years. I think this might be true because we’re now working with a mature chemicals policy and really moving beyond mere hazard management or risk management into sustainability management as well and delivering all of the goals of the Green Deal. That will involve making products more sustainable and creating more sustainable behaviors among consumers and professional and industrial users overall.
What advice would you give to a chemistry student who can see themselves moving away from chemistry slightly and getting more involved with legislation?
First of all, I would advise the student to explore what’s exciting about chemistry. I mean, at the moment, given this whole idea of producing something that’s safe and sustainable by design, there is going to be a massive shift towards considering what the implications of a substance are, not just designing a substance to have a function or an effect. The emphasis will be on thinking about the hazards that it will have by design and to consider how it can be sustainable in its production, how it can be sustainable over its entire lifecycle, and where it might contribute to sustainability gains. I would say spend a few years really delving into the science.
I think something like that is really interesting because if you know the science and you understand the chemistry, then it will be really exciting for you to explore how you can make good policy that enables a competitive playing field for better and greener chemistry for the future.
How important is communication?
Communication is massively important. And it’s one of the reasons why DUCC is celebrating its anniversary. We’re well known to some parts of the European Commission and the European Chemicals Agency, yet we often find that beyond this people might know the products our industries create but they don’t relate them to us as stakeholders. So we really want to communicate what we do, what mixtures are, why they are so important, why it’s important that they are safe and sustainable; and yes, we do want to do that in a clearer and more engaging way.
What do you do in your spare time?
Well, not that I have very much of it these days because my job keeps me very busy. But I am a musician. Many years ago, I trained as a pianist. I am a qualified piano teacher, and although I do not actively teach at the moment, I like to keep my hand in and I like to play the piano to relax. When the Chemicals Strategy for Sustainability becomes just a little too intense at times, then I go and amuse myself with some Beethoven or Chopin or some awesome Debussy. That’s what helps me unwind.
Wow, very impressive! Thank you for the interview.
Jan Robinson studied chemistry and received her degree in applied chemistry in the UK. From 1989 to 1994, she worked as an analytical chemist at Northumbrian Water, Tyneside, UK, and from 1994 to 2009 she held various positions at Akzo Nobel, most recently as QHSE & Regulatory Affairs Manager for the Business Unit Powder Coatings. From 2010 to 2020, she was Director of Product Regulations at the European Council of the Paint, Printing Ink, and Artists’ Colours Industry (CEPE), Brussels, Belgium.
Since 2016, Jan Robinson has been Chair of the Downstream Users of Chemicals Coordination Group (DUCC), Brussels, Belgium, and since 2020 Scientific and Regulatory Affairs Director of the International Association for Soaps, Detergents and Maintenance Products (A.I.S.E.), also based in Brussels.
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